On February 6, 2014, the Commerce Department's Bureau of Industry and Security (BIS) published a Proposed Rule announcing its intent to clarify the responsibilities of parties involved in "routed exports." Delegation of License Requirements Determination and Licensing Responsibility to a Foreign Principal Party, 79 Fed. Reg. 7,105 (Feb. 6, 2014 ) (Proposed Rule).
The Proposed Rule makes three important changes to the Export Administration Regulations (EAR)...
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